This is in response to the June 9, 2011 ODNRA Scoping letter. First off I’d like to thank the Forest Service for pushing this process though public involvement, even though this was already a signed decision. I’ve read through the proposed actions and I feel that there are some excellent changes to the original 10c lands base. With that said I’d like to highlight some other issues that haven’t been addressed with the proposed action.

On March 23, 1972 Congress passed the Act declaring the ODNRA into existence, this act was signed by President Nixon on the 24th. I read through this document and noticed some fairly strong language in Section 12 about an Advisory Council being established by the Secretary of Agriculture. It was fairly specific about the make-up of this council and it appears that they wanted a local body to assist the Forest Service with the direction of these lands. I’ve have spent several hours trying to find any meeting minutes or notes. I question why this council was never established.

Another thing I’d like to point out is how out of date the current plan is. The plan states that it is to be revised every 10 years but no more than 15 years between revisions. This plan is over 17 years old and the 10c designated trails has not been implemented. I ask why now? There are far more important goals outlined within this plan such as an active vegetation management plan implementation. The plan lists this as a higher priority and specifically identifies more funding to accomplish removal of beach grass, scotch broom, and plantations. Remember before the plantations and invasive vegetation these areas were open sand riding areas and not trails; so I question the validity of calling these trails now, instead of dunes where OHV traffic has benefited the ecosystem by hindering the establishment of invasive vegetation.

There is also some other issues with the plan; it seems that the land designations aren’t consistent from one area to the next. There are two similar invasive vegetation created wetland areas one in the north and one in the south that that are listed under two separate land designations, while being very similar. Maybe this is because during the process of this plan the land base was evaluated by aerial photo interpretation instead of being verified on the ground. That would also be why the majority of 10c lands are plantation, beach grass, or other invasive vegetated lands and not globally significant plant communities. In fact OHV traffic will slow the invasive vegetation from overtaking more open sand lands.

To sum this up the Forest Service should seriously be looking at rewriting a management plan with the input of and advisory council before any implementation of trail closure. I think that the closures will cause more ecological damage than the existing situation. The Forest Service should be working with the State of Oregon to come to some sort of agreement about the obliteration of the foredune and filling in the wetlands so that the natural sand migration can once again continue. OHVs are a very small impact to the dunes ecosystem, the real threat is the invasive vegetation and plantations that were planted in the area during the jetty and town construction. The sad thing is that even if the Forest Service closed the ODNRA 100% to OHV use it won’t matter in the next 20 years anyway if there are no measures taken to control the vegetation and reestablish the natural processes of this ecosystem.

The OHV user group is willing and able to assist with whatever is needed to stop this invasion and help return the dunes to their natural state. The forest Service needs to repair the relationship with this group caused from the 94 Dunes plan with education and support